22 October 2019

London Plan Inspectors cut small sites housing target and recommend Green Belt review

The Inspectors examining the draft London Plan have published their report, and there are significant recommended amendments in relation to housing delivery, Green Belt review, and provision of additional industrial capacity.

Small sites and housing delivery

The Inspectors conclude that the proposed presumption in favour of small housing developments (between 1 and 25 homes) and the housing targets associated with these are neither “justified or deliverable” in their current form.

They recommend the reduction of the overall 10 year small sites target for boroughs from 245,730 to 119,250, and accordingly a decrease in the overall 10 year housing target from 649,350 to 522,850. They also recommend the removal of the presumption in favour of small sites.

Green Belt review

In part due to the reduction in small sites targets, the report concludes that existing capacity in London is insufficient to meet the identified annual housing need, and there is also a potential shortfall of industrial land in the medium to long term.

The Inspectors’ “inescapable conclusion” is that a strategic and comprehensive review of all land within the Green Belt is required to meet these challenges, and the report recommends the Plan include a commitment to a Green Belt review, as part of the next London Plan. This is to be led by the Mayor working jointly with the boroughs.

Industrial land supply

The report considers that the approach to meeting industrial development needs is "aspirational but may not be realistic”. As such, it recommends a range of measures to strengthen the policy support for industrial land. While acknowledging that much of this need is long term, and accurately predicting such need is difficult, the report is clear that it considers further land supply will be required, and identifies an “apparent lack of non-Green Belt options for significant new locations for industrial development”.

Given this, the Inspectors recommend the Plan is amended to make express reference to boroughs considering Green Belt reviews through their local plan processes in order to identify sufficient supply of industrial land, in addition to the London-wide Green Belt review to be conducted as part of the future London Pan.

Next steps

The Mayor will now consider the (in our view) substantial recommendations of the report, and submit the Intend to Publish version of the Plan to the Secretary of State. If he does not accept any of the recommendations in the report, he must set out a statement of reasons. The Secretary of State then has a six week period to decide whether or not to direct any changes should be made, before the Plan is laid before the London Assembly.

Providing the London Assembly does not reject the Plan within 21 days (rejection requiring a two thirds majority) the Plan can be published. The Mayor currently anticipates publication of the Plan in February or March 2020.

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